response to portion of rai letter number 20 related to ... · via the reference 1 letter. enclosure...

GE Energy

David H. Hinds

Proprietary and Security Notice Manager, ESBWR

This letter forwards both proprietary and PO Box 780 M/C L60Wilmington. NC 28402-0780

Security-Related information in , USAaccordance with 1OCFR2.390. Upon theremoval of Enclosures 1 and 3, the balance F 910 362 6363

of this letter may be considered non- [email protected]

proprietary and non-Security-Related.

MFN 06-189 Docket No. 52-010Supplement 1

December 8, 2006

U.S. Nuclear Regulatory CommissionDocument Control DeskWashington, D.C. 20555-0001

Subject: Response to Portion of RAI Letter Number 20 Related to ESBWRDesign Certification Application - Seismic Design - RAI Numbers3.7-8S1, 3.7-11S1, 3.7-25S1, 3.7-26S1, 3.7-52S1, and 3.7-55S1 -Supplement 1

Enclosures 1 through 3 contain supplemental responses to the subject RAIs resultingfrom the November 2006 NRC Seismic Audit. GE's original responses were transmittedvia the Reference 1 letter.

Enclosure 1 contains Security-Related information identified by the designation"{{ { Security-Related Information - Withhold Under 10 CFR 2.390}}} ." GE herebyrequests this information be withheld from public disclosure in accordance with theprovisions of 10 CFR 2.390. A public version is contained in Enclosure 2

Enclosure 3 contains GE proprietary information as defined by 10 CFR 2.390. GEcustomarily maintains this information in confidence and withholds it from publicdisclosure.

The affidavit contained in Enclosure 4 identifies that the information contained inEnclosure 3 has been handled and classified as proprietary to GE. GE hereby requeststhat the information of Enclosure 3 be withheld from public disclosure in accordancewith the provisions of 10 CFR 2.390 and 9.17. The Enclosure 3 report is entirelyproprietary and a non proprietary version is not available.

If you have any questions about the information provided here, please let me know.

General Electric Company

MFN 06-189, Supplement 1 of 2

Sincerely,

David H. HindsManager, ESBWR

Reference:1. MFN 06-189, Letter from David Hinds to U.S. ,Nuclear Regulatory Commission,

Response to Portion of RAI Letter Number 20 Related to ESBWR DesignCertification Application - Seismic Design - RAI Numbers 2.5-1, 3.7-5, 3.7-7,3.7-8, 3.7-11, 3.7-12, 3.7-25, 3.7-26, 3.7-29, 3.7-34, 3.7-52, and 3.7-55, June 29,2006

Enclosures:1. MFN 06-189, Supplement 1 - Response to Portion of RAI Letter Number 20

Related to ESBWR Design Certification Application -. Seismic Design - RAINumbers 3.7-8S1, 3.7-11SI, 3.7-25S1, 3.7-26S1, 3.7-52S1, and 3.7-55S1 -Security-Related Information

2. MFN 06-189, Supplement 1 - Response to Portion of RAI Letter Number 20Related to ESBWR Design Certification Application - Seismic Design - RAINumbers 3.7-8S1, 3.7-1IS1, 3.7-25S1, 3.7-26S1, 3.7-52S1, and 3.7-55S1 -PublicVersion

3. MFN 06-189, Supplement 1 - Validation Test Report for DAC3N Version 97,S/VTR-D3N Revision D - GE Proprietary Information

4. Affidavit - George B. Stramback - dated December 8, 2006

cc: AE Cubbage USNRC (with enclosures)GB StrambackGE/San Jose (with enclosures)eDRF 0000-0060-8445

ENCLOSURE 2

MFN 06-189

SUPPLEMENT 1

Response to Portion of RAI Letter Number 20

Related to ESBWR Design Certification Application

Seismic Design

RAI Numbers 3.7-8S1, 3.7-11SI, 3.7-25S1, 3.7-26S1, 3.7-52S1,and 3.7-55S1

Public Version

MFN 06-189, Supplement I Page 2 of 25Enclosure 2

NRC RAI 3.7-8

In DCD Section 3.7.].1 and DCD Section 3.7.1.1.1, respectively, the applicant stated thatfor generic site (1) the peak ground acceleration (PGA) of the SSE is 0.3g at thefoundation level, and (2) the design response spectra are specified at the foundation levelin the free field It is the staff's understanding that the foundation level of thereactor/fuel building is located at 20m (66. Oft) below grade and the foundation level ofthe control building is located at 15.05 m (49ft) below grade. The applicant is requestedto provide its technical basis to justify why the PGAs and ground response spectra arethe same at these two (2) different foundation elevations.

GE Response

The use of the same 0.3g RG 1.60 spectra at different foundation elevations is aconservative approach for developing enveloping seismic loads for the ESBWR standardplant design. In COL a site-specific SSE probabilistic site response analysis will beperformed and the resulting free-field outcrop spectrum at the foundation level of eachSeismic Category I building will be compared to the ESBWR standard plant designspectrum as stated in the response to RAI 3.7-5.

Please note that the embedment depths are 20m for the reactor and fuel buildings and14.9m for the control building.

A markup of DCD Tier 2 Section 3.7.1.1.3, DCD Tier 2 Tables 3.8-13 and 3A.2-1 wasprovided under MFN 06-189.

MFN 06-189, Supplement IEnclosure 2

NRC RAI 3.7-8. Supplement 1

Page 3 of 25

NRC Assessment Following the November 2,2006 Audit

Demonstrate conservatism in the approach for developing enveloping seismic loads.

GE Response

The first paragraph of the response provided in MFN 06-189 is revised as follows toremove the reference to conservatism:

"0.3g RG 1.60 spectra at different foundation elevations is the approach used fordeveloping enveloping seismic loads for the ESBWR standard plant design. In COL asite-specific SSE probabilistic site response analysis will be performed and the resultingfree-field outcrop spectrum at the foundation level of each Seismic Category I buildingwill be compared to the ESBWR standard plant design spectrum as stated in the responseto RAI 3.7-5."

No DCD change will be made in response to. this RAI Supplement.


NRC RAI 3.7-11

In the fourth sentence of the first paragraph of DCD Section 3.7.1.1.3 (Page 3.7-4), theapplicant stated that, since the low frequency part of North Anna SSE ground responsespectra are enveloped by the 0. 3g RG 1.60 generic site response spectra with largemargins, only the high frequency part needs to be explicitly taken into account. The staffrequests the applicant to provide justifications for the conclusion drawn in the DCD anda comparison plot of these two sets of ground response spectra in Tier 2 DCD Section3.7.1, "Seismic Design Parameters."

GE Response

The spectra of Figure 3.7-7 (1) are the envelops of high and low frequency target spectraused to define outcrop ground motions at horizons within the site rock profile. Figure3.7-11 (1) reproduces the CB and RB/FB spectra of Figure 3.7-7 (1) and adds RG 1.60anchored to a PGA of 0.3g. Comparison of this figure with DCD Figure 2.5-1 impliesthat the high frequency target spectra (shown in DCD Figure 2.5-1) control motions forfrequencies above about 2 Hz, and that the low frequency target spectra (enveloped bythe low frequency part of the spectra in Figure 3.7-7 (1) above) control motions for lowerfrequencies. It is apparent that the RG 1.60 spectrum envelopes by a factor of over 5 thelow frequency part of the site-specific ground motion spectra for all -evaluated NorthAnna Early Site Permit horizons (including the CB and RB/FB base horizons).

No DCD change was required for this RAI response.


Page 5 of 25

Comparison of Rock Spectra at Five Depths - With RG 1.60

10

0.1

0

(Ua-00UU

a-U0a.

U)

0.01

0.001

0.1 1 10Frequency (Hz)

100

Figure 3.7-11 (1) - Comparison of North Anna ground motion spectra at the CB andRB/FB (and other) horizons with a RG 1.60 spectrum anchored to 0.3g PGA.


NRC RAI 3.7-11, Supplement 1

NRC Assessment Following the November 2, 2006 Audit

Provide additional clarification for the second sentence description provided in the lastresponse submitted

GE Response

The response provided in MFN 06-189 is revised as follows to clarify the response:

"The spectra of Figure 3.7-7 (1) are the envelops of high and low frequency target spectraused to define outcrop ground motions at horizons within the site rock profile. Figure 3.7-11 (1) reproduces the CB and RB/FB spectra of Figure 3.7-7 (1) and adds RG 1.60anchored to a PGA of 0.3g. It is apparent that the RG 1.60 spectrum envelopes by afactor of over 5 the low frequency part of the site-specific ground motion spectra for allevaluated North Anna Early Site Permit horizons (including the CB and RB/FB basehorizons)."

No DCD change will be made in response to this RAI Supplement.


NRC RAI 3.7-25

For the development of the RB/FB seismic model, the staff requests the applicant tospecify in the DCD where the heavy crane (with trolley) is to be parked during plantoperation. This information is needed to properly locate the mass and assess the effectsof mass eccentricity in the seismic analysis. This information also needs to be identifiedas an interface item for the COL applicant.

GE Response

For the development of the RB/FB seismic model, the heavy crane (with trolley) isassumed to be parked between col-rows R3 and R4 in the RB and between col-rows FBand FC in the FB.

In order to assess the effects of crane location in the seismic analysis, the change of masseccentricity was calculated varying the crane locations. A worst location is considered inthe sensitivity analysis. Figure 3.7-25(1) shows the changes of the centers of gravity atthe RB and FB crane floors. The centers of gravity moved only 25 cm maximum. Table3.7-25 (1) shows comparison of eigenvalue analysis results for RBFB model in Fixed-base case. It is found that the difference of frequencies due to the crane location isnegligibly small.

Hence, there is no need to identify crane location as an interface item for the COLapplicant.

No DCD change was required in response to this RAI.


Page 8 of 25

(a) EL 34.00

(b) EL 13.57

Figure 3.7-25 (1) - Crane Location for Seismic Analysis


Page 9 of 25

Table 3.7-25 (1) - Comparison of Eigenvalue Analysis Results for RBFB Modelin Fixed-base Case

FREQUENCY (Hz)IMODE F Difference

DCD*' Worst*2

2.74

3.81

3.81

3.94

4.36

5.21

5.22

5.98

5.99

6.09

6.75

8.02

8.58

10.24

10.32

10.52

10.67

11.23

11.25

11.89

12.26

12.28

12.56

12.82

13.38

13.73

14.86

15.44

15.88

16.25

2.74

3.81

3.81

3.94

4.36

5.21

5.22

.5.98

5.99

6.09

6.75

8.01

8.58

10.24

10.32

10.52

10.67

11.23

11.25

11.89

12.26

12.28

12.56

12.82

13.37

13.72

14.86

15.43

15.89

16.25

0.00%

0.00%

0.00%0.03%

0.02%

0.00%

0.00%

0.00%

0.00%

-0.03%

0.00%

0.06%0.04%

-0.02%

0.00%

0.00%

0.03%

0.00%

0.00%0.00%

-0.01%

0.00%-0.02%

-0.03%

0.05%

0.06%

0.01%

0.08%

-0.02%

0.00%

Note: Assumed crane locations are shown in Figure 3.7-25 (1).* 1: Crane location assumed in DCD.

*2: Worst location for impact evaluation.

MFN 06-189, Supplement 1 Page 10 of 25Enclosure 2

NRC RAI 3.7-25. Supplement 1

NRC Assessment Followin2 the November 2,2006 Audit

Describe the effect of location of the main RB crane parking location on the design loadsfor individual structural members.

GE Response

For the NASTRAN stress analysis, the crane locations are assumed as shown in Figures3.7-25 (1) and 3.7-25 (2). The column R3/RB (i.e. column at the intersection of grid lineR3 and grid line RB) and column R4/RB support the heaviest load from the RB crane.The columns F3/FB and F3/FC support the heaviest load from the FB crane., By usingthe stresses obtained from the stress analyses for these heaviest loaded columns, all thecolumns are designed and sized for the worst loading possible. Therefore, the crane canbe parked anywhere from a structural design viewpoint.

No DCD change will be made in response to this RAI Supplement.


Page 11 of 25

Figure 3.7-25 (1) Assumed Location for RB Crane{{{Contains Security-Related Information - Withheld Under 10 CFR 2.390}}}

MFN 06-189, Supplement 1Enclosure 2

Page 12 of 25

Figure 3.7-25 (2) Assumed Location for FB Crane{{{Contains Security-Related Information -Withheld Under 10 CFR 2.390}}}


Page 13 of 25

NRC RAI 3.7-26

For seismic subsystem analysis, accurate in-structure response spectra are neededat thesubsystem support points. The staff requests the applicant to describe in the DCD how ithas considered the effects of out-of-plane vibration of floors and walls in the seismicstructural models and the development of in-structure response spectra.

GE Response

As described in DCD Appendix 3A.7, a finite element model was used to obtain thevertical floor frequencies at major floor locations. The obtained frequencies wereincluded in the stick model by a series of vertical single degree-of-freedom oscillators atthe corresponding floor elevations. The in-structure response spectra were calculatedusing the oscillator responses.

Compared to the floors, the out-of-plane vibration frequencies of walls, which supportsubsystem designed using in-structure response spectra, are very high. Table 3.7-26 (1)shows the calculated out-of-plane fundamental frequencies for the typical walls in theRBFB. It is found from the calculations that the out-of-plane fundamental frequenciesfor the walls are higher than the highest frequency of interest at 50 Hz. Therefore, theeffects of out-of-plane vibration of walls are not considered in the seismic structuralmodels.

No DCD change was required for this RAI response.

Table 3.7-26 (1) - Out-of-plane Fundamental Frequencies for Typical Walls

Building Elevation (m) Wall Thickness (m) Frequency (Hz)

RBFB EL -11.5 to EL-6.4 2.0 224

RBFB EL-4.65 to EL -9.06 1.5 183

RBFB EL27.0 to EL 34.0 1.0 68

RBFB Above EL 34.0 1.0 53

CB EL-2.0 to EL4.65 0.9 60

MFN 06-189, Supplement 1 Page 14 of 25Enclosure 2



Review calculations for out-of-plane vibrations and document the results.

GE Response

The out-of-plane vibration frequencies of walls were reviewed. As shown in Table 3.7-26 (1), the calculated out-of-plane fundamental frequencies for the typical walls in theRBFB and the CB are higher than the highest frequency of interest of 50 Hz. However,since the RB walls above the refueling floor at EL 34.Om and the FB walls at EL 4.65mhave large heights to the upper floor, their frequencies are expected to be lower than 50Hz. They are evaluated by using FEM model in the same manner as the slab frequencies.,The eigenvalue analysis results are shown in Tables 3.7-26 (2) and 37-26 (3). Theirmode shapes are shown in Figures 3.7-26 (1) through 3.7-26 (8).

To obtain design loads of these walls and design FRS for the components attached tothese walls, seismic analysis will be performed using wall oscillators calculated by theabove analysis, in the same manner as floor oscillators. The seismic analysis model isshown in Figure 3.7-26 (9). The cracked concrete effect will be addressed by reducingthe oscillator's spring values by 50%.

DCD Tier 2 Appendix 3A will be revised to include the results of this analysis in the nextupdate.


Page 15 of 25

Table 3.7-26 (1) Out-of-plane Fundamental Frequencies for Typical Walls

Building Elevation (m) Wall Thickness (m) Frequency (Hz)

RBFB EL -11.5 to EL-6.4 2.0 224

RBFB EL-4.65 to EL -9.06 15 183

RBFB EL27.0 to EL 34.0 1.0 64

CB EL-2.0 to EL4.65 0.9 60

Table 3.7-26 (2) Eigenvalue Analysis Results for RB Walls above EL34000

Effective Weight Average Total Weight StiffnessMode Frequency (MN)~ Group Frequency Note

No. (Hz) RI No. (MN) (MN/rn)

RI RB (Z

1 14.14 0.00 4.56 1-RB 14.14 4.56 (38.0%) 3666 RB

2 15.14 7.16 0.00 I-R1 15.87 8.13 (93.1%) 8238 RI

3 17.23 0.00 0.00

4 21.22 0.97 0.01 RI

5 21.88 0.00 1.41 2-RB 24.51 5.10 (42.5%) 12332 RB

6 25.29 0.00 2.44 RB

7 25.95 0.00 1.25 RB

8 26.99 0.00 0.01

9 30.63 0.00 0.00

10 35.22 0.54 0.01 2-RI 35.22 0.54 (6.2%) 2714 RI

11 38.07 0.01 0.56 3-RB 43.36 2.28 (19.0%) 17234 RB

12 39.44 0.01 0.00

13 40.40 0.00 0.01

14 40.88 0.00 0.00

15 41.73 0.00 0.02

16 42.51 0.00 0.00

17 43.61 0.01 0.01

18 44.12 0.00 0.37 RB (to 3-RB)

19 45.59 0.00 0.02

20 47.49 0.02 0.02

21 48.01 0.00 1.30 RB (to 3-RB)

RI Total 8.7MN Total 8.7MN (99.3%)

RB Total 12.OMN Total 11.9MN (99.4%)

Note: R7 wall is considered to be identical to RI wall. RF wall is considered to be identical to RB wall.


Page 16 of 25

Table 3.7-26 (3) Eigenvalue Analysis Results for FB Walls above EL4650

Effective Weight Average Total Weight StiffnessMode Frequency (MN Group Frequency Note

No. (Hz) No. (e ) (MN) (MN/rn)

F3 .FA

1 12.73 8.09 0.01 1-F3 12.73 8.09 (73.7%) 5278 F3

2 13.27 0.01 4.93 1-FA 13.27 4.93 (85.0%) 3493 FA

3 15.98 0.60 0.00 2-F3 18.34 2.38 (21.7%) 3225 F3

4 19.14 1.78 0.00 F3

5 23.65 0.00 0.00

6 25.75 0.03 0.00

7 29.23 .0.00 0.00

8 33.32 0.04 0.00 3-F3 35.36 0.23 (2.1%) 1170 F3

9 35.79 0.19 0.00 F3

10 36.55 0.01 0.00

11 37.55 0.00 0.00

12 37.69 0.01 0.00

13 40.73 0.00 0.86 2-FA 40.73 0.86 (14.8%) 5733 FA

14 42.50 0.20 0.00 4-F3 42.50 0.21 (1.9%) 1522 F3'

15 .49.87 0.01 0.00

F3 Total I .OMN Total 10.9NMN (99.5%)

FA Total 5.8MN Total 5.8MN (99.8%)

Note: FF wall is considered to be identical to FA wall.


Page 17 of 25

Figure 3.7-26 (1) RB Walls above EL34000 Mode 1



Page 18 of 25



MN/E06-189, Supplement I Page 19 of 25Enclosure 2

Figure 3.7-26 (5) FB Walls above EL4650 Mode I

.Figure 3.7-6 (6) FB Walls ae EL4650 Mode 2


Page 20 of 25

Figure 3.7-26 (7) FB Walls above EL4650 Mode 3

~- ~~1

Figure 3.7-26 (8) FB Walls above EL4650 Mode 13


Page 21 of 25

838B====L= 847RBFB 9101-9108

w110EL 52400

110

RB, RF mi.

EL 42000

RI, R7 wag

109EL 34000 4

F,1109

9084

EL 27000 9084

9071-9075

EL 22500

09061,9062

EL 17500 . Z

FA, FF wall 90u

EL 13570

F, 1105z 190',

F3 wag

EL 9060 104

90319034,901 _g

EL 4650103

9021.9 022,9026 5~

19021 9022 9026

EL -1000

F1 10.2

EL -6400 4

F1101,

858

859

860

828

RCCV0 9091 9081

903918310

Fg9999

ri o

Detail A9081-9083

800120 .......................... .... ...---_ .•

4 EL 24180707

0107 1208

11077 90659165 VentWall ,EL20200

90639163 6 90649 708

...... .qF - -. - 1701106 9999ig 206 999 EL 1750

2915290 9051 9151 40 EL 15775

9206 EL 14500 709

-105 9999 1205

9142 9042 9041 9141 EL 11500 703 EL 11350710

204 E 50 704110 9 1204 700 EL.746

15913 90359029132 9033 903329133 7119708

S --. .-.---..----- ==~ EL 4650 1- g99 99 0 F9999] 303 -

1103 120 1303 L 2416"59027 912 37 =! EL 1960'

259125 90259023 E 79024,9124 EL-800 7

908 9024102 99991 202 9999 302 EL.2753

Pedestal

2 9

l7~l

811

808807

808

8100

814

829

831

832833

834

2:.5 a5) 915 838 . 847

851'12

5S 844 854713

714 82------------48 8515 K(4 K8 827 8515 82682

"9 ---.19 B6 F0 868

1871 872

A

SRigid Link for the directions of X, Y. Z, Rx, Ry and Rz.

Z direction is not linked.EL -11500

EL -15500F

Of10-211

Note: Refer to Figures 8.2-1 through 8.2-3 for details of individual stick'seccenFicigies.

Figure 3.7-26 (9) RBFB Complex Seismic Model including Wall Oscillators


NRC RAI 3.7-52

DCD Section 3.7.3.13 does not provide any detail about the methods of analysisemployed or the acceptance criteria used to determine structural design adequacy ofburied conduits, tunnels, and auxiliary systems. In addition, the applicant did not providethe definition for the term "auxiliary systems. " The staff requests the following additionalinformation to complete its review:

(a) a description of the types of SSCs that are included under the category "auxiliarysystems;"

(b) a description of the analysis method and acceptance criteria for buried conduits;.

(c) a description of the analysis method and acceptance criteria for tunnels,

(d) a description of the analysis method and acceptance criteria for auxiliary systems.

GE Response

(a) See DCD Table 3.2-1 for identification of components in "auxiliary systems". See

DCD Chapter 9 for identification and description of "auxiliary systems."

(b) There are no Seismic Class I buried conduits.

(c) There are no C-I tunnels in the ESBIWR design. Tunnels in the ESBWR are NS butsince some tunnels in the ESBWR carry liquid radwaste, the structural acceptanceand materials criteria for tunnels are in accordance with RG 1.143 - Safety Class Ila.The method of seismic analysis is the same as building embedded walls, taking intoaccount the requirements described in DCD Section 3.7.3.13.

(d) Same analysis methods and acceptance criteria is used for Auxiliary systems forunderground portions of Category I structures, as shown in DCD Sections 3.8.4 and3.8.5 for analysis and acceptance criteria details. Refer to DCD Chapter 9 for list ofauxiliary systems.

Markups of DCD Tier 2 Sections 3.7.3.13, 3.7.3.14 and 3.7.3.15 were provided in MFN06-189.


NRC RAT 3.7-52, Supplement 1


Provide an explicit description of the design approach and acceptance criteria for buriedC-1 SSCs since there are electrical cable banks between the CB and RB.

GE Response

The responses provided to RAI 3.7-52 (b) and (c) under MFN 06-189 are revised asfollows:

(b) There are no Seismic Class I buried conduits. There are Seismic Class I conduitsin two electrical duct banks from the CB to the RB.

(c) There are no C-I tunnels in the ESBWR design. The access tunnels betweenSeismic Category I or II buildings are C-II. Tunnels carrying liquid radwaste areNS but the structural acceptance and material criteria are in accordance with RG1.143 - Safety Class Ha.

The electrical duct banks (See (b) above) and yard FPS lines are buriedunderground utilities with a Seismic Category I classification. The duct banks arelocated in a closed reinforced concrete trench (or tunnel) covered with backfilland the FPS lines will be located in covered reinforced concrete trenches near thesurface with removable covers to facilitate maintenance and inspection access.These items are relatively short since they are routed directly between buildings.

The method of seismic analysis is the same as building embedded walls, takinginto account the requirements described in DCD Tier 2 Subsection 3.7.3.13. Theeffect of wave propagation is accounted for in accordance with Section 3.5.2 andCommentary of ASCE 4-98.

No DCD change is required in response to this RAI supplement.


Page 24 of 25

NRC RAI 3.7-55

To facilitate the staff's evaluation of the adequacy of computer codes used for design andanalysis of the ESBWR Seismic Category I structures, the staff requests the applicantsubmit validation packages, translated into English, for the following computer codeslisted in DCD Appendix 3C:

SSDP-2D

TEMCOM2

DAC3N.

GE Response

The following validation packages were enclosed in Attachments 3.7-55(1) through (3)under MFN 06-189. These documents were prepared according to Shimizu QA program.

(1) S/VTR-SD2, Validation Test Report for SSDP-2D, Rev. C.

(2) S/VTR-D3N, Validation Test Report for DAC3N, Rev. C.

(3) S/VTR-TEM, Validation Test Report for TEMCOM2, Rev. C.

No DCD change was required in response to this RAI.



NRC Assessment Following the November 2. 2006 Audit

Use a large size problem for comparison of results obtained from a commerciallyavailable program since the test cases for DAC3N computer code validation are toosimple to test the problem size limitation, if any, of the code. State the validation status ofthe commercial program used.

GE Response

The following validation report, included as Attachment 3.7-55 (4), has been revised toinclude a large size problem for comparison of results obtained from NASTRAN, whichis a commercially available program:

1) S/VTR-D3N, Validation Test Report for DAC3N, Rev. D

For the commercial programs used -- SASSI and SHAKE, the computer code vendor UC-Berkeley, performed the code validation. The validation status of other commercialprograms used is provided in DCD Tier 2 Appendix 3C.

DCD Tier 2 Appendix 3C will be revised in the next update as noted in the attachedmarkup.

26A6642AL Rev. 03ESBWR Design Control Document/Tier 2

Lysmer. The program is based on the finite-element method formulated in the frequency domain

using a substructuring technique.

3C. 7.2.2 Validation

SASSI version 2000 was obtained from the University of California, Berkeley and implementedby Shimizu Corporation of Tokyo, Japan on the PC computer on Linux OS. Program validationdocumentation is available at UC Berkeley.

3C. 7.2.3 Extent of Application

SASSI is used to obtain seismic design loads and in-structure floor response spectra for theSeismic Category I buildings accounting for the effects of SSI.

3C.7.3 Free-Field Site Response Analysis - SHAKE3C. 7.3.1 Description

SHAKE is a program, which can perform the free-field site response analysis. It was developedat the University of California, Berkeley by B. Schnabel, John Lysmer and H.B. Seed in 1972.The program is based on the theory of one-dimensional propagation of shear waves in thevertical direction in a horizontally-layered visco-elastic soils system overlying an elastic half-space medium.

SHAKE also has a function to account for non-linearities in soil shear modulus and hysteresisdamping as functions of shear strain in soil by the use of equivalent-linear soil properties usingan iterative equivalent linearization procedure to obtain constant values of shear modulus andhysteresis damping ratio compatible with the effective shear strain in each soil layer.

3C. 7.3.2 Validation

SHAKE was developed at the University of California, Berkeley and implemented by ShimizuCorporation of Tokyo, Japan on the Hewlett Packard computer workstation. Program validationdocumentation is available at UC Berkeley.

3C. 7.3.3 Extent of Application

SHAKE is used to generate the free-field site response motions required in the seismic SSIanalysis.

3C-4

ENCLOSURE 4

MFN 06-189

Supplement 1

Affidavit



AFFIDAVIT

I, George B. Stramback, state as follows:

(1) I am Manager, Regulatory Services, General Electric Company ("GE") and havebeen delegated the function of reviewing the information described in paragraph (2)which is sought to be withheld, and have been authorized to apply for itswithholding.

(2) The information sought to be withheld is contained in Enclosure 3 of GE letter MFN06-189, Supplement 1, David H. Hinds to NRC, Response to Portion of RAI LetterNumber 20 Related to ESBWR Design Certification Application - Seismic Design -RAI Numbers 3.7-8S1, 3.7-11S1, 3.7-25S], 3.7-26S1, 3.7-52S1, and 3.7-55S] -Supplement 1, dated December 8, 2006. The proprietary information in Enclosure 3,Validation Test Report for DAC3N Version 97, S/VTR-D3N Revision D, contains thedesignation "GE Proprietary Information {3 }" on each page. The notation {3} refersto Paragraph (3) of this affidavit, which provides the basis for the proprietarydetermination.

(3) In making this application for withholding of proprietary information of which it isthe owner, GE relies upon the exemption from disclosure set forth in the Freedom ofInformation Act ("FOIA"), 5 USC Sec. 552(b)(4), and the Trade Secrets Act, 18USC Sec. 1905, and NRC regulations 10 CFR 9.17(a)(4), and 2.790(a)(4) for "tradesecrets" (Exemption 4). The material for which exemption from disclosure is heresought also qualify under the narrower definition of "trade secret", within themeanings assigned to those terms for purposes of FOIA Exemption 4 in,respectively, Critical Mass Energy Project, v. Nuclear Regulatory Commission,975F2d87l (DC Cir. 1992), and Public Citizen Health Research Group v. FDA,704F2d1280 (DC Cir. 1983).

(4) Some examples of categories of information which fit into the definition ofproprietary information are:

a. Information that discloses a process, method, or apparatus, includingsupporting data and analyses, where prevention of its use by General Electric'scompetitors without license from General Electric constitutes a competitiveeconomic advantage over other companies;

b. Information which, if used by a competitor, would reduce his expenditure ofresources or improve his competitive position in the design, manufacture,shipment, installation, assurance of quality, or licensing of a similar product;

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c. Information which reveals aspects of past, present, or future General Electriccustomer-funded development plans and programs, resulting in potentialproducts to General Electric;

d. Information which discloses patentable subject matter for which it may bedesirable to obtain patent protection.

The information sought to be withheld is considered to be proprietary for the reasonsset forth in paragraphs (4)a., and (4)b, above.

(5) To address 10 CFR 2.390 (b) (4), the information sought to be withheld is beingsubmitted to NRC in confidence. The information is of a sort customarily held inconfidence by GE, and is in fact so held. The information sought to be withheld has,to the best of my knowledge and belief, consistently been held in confidence by GE,no public disclosure has been made, and it is not available in public sources. Alldisclosures to third parties including any required transmittals to NRC, have beenmade, or must be made, pursuant to regulatory provisions or proprietary agreementswhich provide for maintenance of the information in confidence. Its initialdesignation as proprietary information, and the subsequent steps taken to prevent itsunauthorized disclosure, are as set forth in paragraphs (6) and (7) following.

(6) Initial approval of proprietary treatment of a document is made by the manager ofthe originating component, the person most likely to be acquainted with the valueand sensitivity of the information in relation to industry knowledge. Access to suchdocuments within GE is limited on a "need to know" basis.

(7) The procedure for approval of external release of such a document typically requiresreview by the staff manager, project manager, principal scientist or other equivalentauthority, by the manager of the cognizant marketing function (or his delegate), andby.the -Legal Operation, for technical content, competitive effect, and determinationof the accuracy of the proprietary designation. Disclosures outside GE are limited toregulatory bodies, customers, and potential customers, and their agents, suppliers,and licensees, and others with a legitimate need for the information, and then only inaccordance with appropriate regulatory provisions or proprietary agreements.

(8) The information identified in paragraph (2), above, is classified as proprietarybecause it 'contains detailed ESBWR design information developed by GE and/or itspartners over a period of several years at a cost of over one million dollars. Thisinformation, if used by a competitor, -would reduce his expenditure of resources orimprove his competitive position in the design, manufacture, shipment, installation,assurance of quality, or licensing of a similar product.

(9) -Public disclosure of the information sought to be withheld is likely to causesubstantial harm to GE's competitive position and foreclose or reduce theavailability of profit-making opportunities. The information is part of GE'scomprehensive BWR safety and technology base, and its commercial. value extends

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beyond the original development cost. The value of the technology base goesbeyond the extensive physical database and analytical methodology and includesdevelopment of the expertise to determine and apply the appropriate evaluationprocess. In addition, the technology base includes the value derived from providinganalyses done with NRC-approved methods.

The research, development, engineering, analytical and NRC review costs comprisea substantial investment of time and money by GE.

The precise value of the expertise to devise an evaluation process and apply thecorrect analytical methodology is difficult to quantify, but it clearly is substantial.

GE's competitiveý advantage will be lost if its competitors are able to use the resultsof the GE experience to normalize or verify their own process or if they are able toclaim an equivalent understanding by demonstrating that they can arrive at the sameor similar conclusions.

The value of this information to GE would be lost if the information were disclosedto the public. Making such information available to competitors without theirhaving been required to undertake a similar expenditure of resources would unfairlyprovide competitors with a windfall, and deprive GE of the opportunity to exerciseits competitive advantage -to seek an adequate return on its large investment indeveloping these very valuable:analytical tools.

I declare under penalty of perjury that the foregoing affidavit and the matters statedtherein are true and correct to the best of my knowledge, information, and belief.

Executed on this 81h day of December 2006.

George B.$trambackGeneral Electric Company

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